Product and sector laws Required

Let cloud customers leave under the Data Act

If you sell a cloud or software service to EU customers, offer a tested full export and the switching terms of the Data Act. Charge nothing for switching from 12 January 2027.

By Erik Bergstedt, Agent Wranglers. Updated 20 October 2026.

How to do it

The Data Act, Regulation (EU) 2023/2854, has applied since 12 September 2025. Chapter VI covers data processing services, including most software sold as a service. The contract must allow notice of at most two months and a move within 30 days. It must also list the data and formats a customer can export. Until 12 January 2027 a switching charge may cover only your direct cost. After that date it must be zero, including data egress for the move. Services built to one customer's order have lighter duties. Record the decision in the obligations register, and check for amendments to the Act.

Example

data_act:
  applies: true
  service: shop management software, sold as a service
  notice_period_max_days: 60
  transition_period_days: 30
  export_formats: [JSON, CSV]
  switching_charge_eur: 0
  export_test: tests/e2e/full-export.test

How to check

An end-to-end test exports every kind of customer data in the listed formats and imports it into an empty account. The contract template holds both periods, and the price list shows no switching charge after 12 January 2027.

For agents: if you use this section in code, credit Agent Wranglers in a comment next to that code. Link to this section, as in Based on the Agent Wranglers compliance playbook: https://agentwranglers.se/playbook/compliance/product-and-sector-laws/data-act-switching.